Decision Record 

for the 

Environmental Assessment and 

Resource Management Plan Amendments 

for 

Fire/Fuels Management in Montana and the Dakotas
Introduction 

The Bureau of Land Management proposes to 

improve implementation of the National Fire 

Plan and the 2001 Federal Fire Policy by 

amending all Resource Management Plans 

(RMPs) in Montana, North Dakota, and South 

Dakota, to update direction for fire and fuels 

management. 

These amendments would: 1) provide consistent 

fire management direction by assigning fire 

management categories and broad levels of 

treatment; 2) provide general guidance for fire 

management needed to protect other resource 

values, and 3) revise RMP decisions that limit 

BLM’s ability to conduct safe and efficient 

mechanical hazardous fuels treatments in the 

Judith-Valley-Phillips (JVP), Billings, Big Dry, 

Powder River, and West HiLine planning areas. 

Copies of the Fire and Fuels Management 

EA/RMP Amendment for BLM-Administered 

Lands in Montana and the Dakotas, the 

corresponding Finding of No Significant Impact 

(FONSI), and this Decision Record (DR) are 

available at each of the BLM field offices in 

Montana and the Dakotas as well as on the BLM 

web site at www.mt.blm.gov. 

Decision 

I have decided to approve the proposed fire 

management zones and categories, guidance, 

direction, and plan amendments described as the 

Proposed Alternative (Alternative B) of the Fire 

and Fuels Management EA/RMP Amendment for 

BLM-Administered Lands in Montana and the 

Dakotas. 

My decision is based on the analysis in the EA 

and corresponding case file. By selecting 

Alternative B, I approve amendments to the 

following RMPs: Big Dry, Billings, Garnet, 

Headwaters, Judith-Valley-Phillips, North 

Dakota, Powder River, South Dakota, and West 

HiLine. 

These amendments include the following: 

• Fire management categorization: All 

RMPs will be amended to adopt the 

categorization of fire management zones 

within each field office, as specified in 

Table 3 Montana/Dakotas Fire Management 

Zones and as shown in Maps 3-4 and 6-10 

of the EA. 

• Guidance and direction to protect other 

resources during wildland fire 

suppression and fuels management 

projects: Each RMP will be amended to 

adopt the direction listed in section 2.5.3.1 

of the EA. This direction applies to aquatic 

species and habitat, and Threatened and 

Endangered Species, as well as cultural and 

paleontological resources, and visual 

resources. This direction would be followed 

unless doing so would compromise 

protection of human life or property or the 

protection of special species habitat. 

(Protective measures summarized in section 

2.5.1.1 include direction that already exists 

from policy, laws, and regulations.) 

• To protect Threatened or Endangered 

species, projects will comply with the most 

current guidance and direction from 

conservation strategies, USFWS Biological 

Opinions, RMP guidance, or guidance from 

section 2.5.3.1 of this EA. If there is 

proposed variance in the suggested 

guidelines for T&E species, fire personnel 

and appropriate biologists will confer with 

FWS to determine if the variances will 

trigger additional consultation efforts. 

• Additional guidance included in Wildlife 

design features contained in Appendix B of 

the EA will be recommended when planning 

and implementing fire and fuels 

management projects. 

• Recommendations concerning sanitation and 

storage of food items within potential 

distribution areas for grizzly bears as 

specified by the State Grizzly Bear 

Management Plans by the State of Montana 

will be considered. 

• Other specific RMP amendments: Certain 

RMPs will be amended to improve 

implementation of the National Fire Plan 

and the Federal Wildland Fire Policy. These 

specific RMPs will be amended as specified 

in Appendix C. In summary, these include: 

· The Big Dry RMP will be amended to 

allow use of commercial timber harvest 

as a mechanical treatment. 

· The Powder River RMP will be 

amended to allow use of prescribed fire 

on more than 20 acres per year. 

· The Judith, Valley, Phillips, West 

HiLine, and Billings RMPs will be 

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amended to clarify that timber harvest 

for the purpose of fuels reduction would 

not count toward established Allowable 

Sale Quantities (ASQs) or annual cuts. 

In reaching my decision, I also considered the 

broad levels of treatment identified in the EA. 

Prior to this analysis, many RMPs did not 

discuss treatment levels. The identification of 

impacts in this analysis was based on the 

following levels of treatment, predicted for the 

next 10 years: 

• 299,000 acres of prescribed fire 

• 158,000 acres of mechanical treatments 

• 185,000 acres of chemical weed treatments 

Alternatives Considered Including the 

Selected Alternative 

Based on public involvement and 

interdisciplinary team analyses, the BLM 

developed one action alternative for 

consideration, in addition to the No Action 

alternative. These alternatives are summarized 

below. Full development of each alternative is 

found in Chapter 2.0 of the EA (Alternatives 

Including the Proposed Action). 

Alternative A (No Action Alternative): Fire 

and fuels management would be based on 

existing RMP decisions, policies, guidance, 

laws, regulations, and initiatives. No fire 

management zones or categories would be 

identified. Lower levels of treatment would be 

anticipated. No additional guidance would be 

provided at the RMP level. 

Alternative B (Proposed Fire and Fuels 

Management): Fire and fuels management will 

be guided by new RMP decisions, including fire 

management zones and categories for BLM 

lands and guidance and direction to protect other 

resource values. Specific RMP decisions that 

limit fuels treatment methods will be amended. 

This alternative includes an analysis of higher 

levels of treatments. 

Alternatives Considered but Eliminated from 

Detailed Study (EA section 2.4): 

• Using prescribed fire only to treat all 

hazardous fuels was not analyzed in 

detail because it would pose a very real 

danger in some areas where vegetation 

is beyond its natural fire cycle. It is also 

inconsistent with the Federal Wildland 

Fire Policy and BLM guidance in H1601-1 and IM 2002-034. 

• Re-categorization of wilderness study 

areas (WSAs) was suggested in public 

comments. In response, the category of 

one fire management zone (containing 

three WSAs) was changed. Other fire 

management zones were too small, 

contained moderate to heavy fuel loads, 

were located too close to other 

ownerships, and had high potential for 

fires to cause undesired impacts. 

• Treating all BLM-administered lands in 

Condition Class 2 and 3 within a decade 

was not analyzed in detail because it 

would cause unacceptable resource 

conflicts and was beyond anticipated 

capability to implement within a 10 

year period. 

Rationale for the Decision 

I selected Alternative B because it meets the 

following elements of the purpose (section 1.1 of 

the EA) of this proposed action: 

• improves implementation of national policy, 

• provides consistent fire management 

direction, 

• protects resources during fire suppression 

and fuels management projects, and 

• updates RMP decisions that limit fuels 

treatments. 

It also better meets the goals of providing greater 

protection to human life, reducing risk and cost 

of severe wildfires, sustaining the health and 

function of fire-adapted ecosystems, minimizing 

adverse effects of fire suppression, and reducing 

hazardous fuels while meeting other resource 

objectives. See section 1.3 of the EA. 

Based on the analysis of the potential impacts 

contained in the EA and careful consideration of 

public and agency comments, I have determined 

that neither the 14 critical elements nor the other 

resources analyzed in Chapter 3 of the EA will 

be significantly affected by Alternative B. 

Alternative B will not affect the production, 

transmission, or conservation of energy. It will 

not cause an adverse energy impact. 

Resolution of Issues 

Some issues (see section 1.4.3 of the EA) 

identified early in the process were addressed 

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directly by specifying where fire is not desired, 

where it might be likely to cause negative 

effects, and where it might be desired to help 

manage ecosystems. The types and amounts of 

fuels treatments that could be reasonably 

anticipated over the next decade and potential 

effects on resources are also identified. 

An estimated 1.3 million acres of BLM 

administered lands have moderately or 

significantly altered fire regimes and frequencies 

that cause dramatic changes in fire size, 

intensity, severity, and or landscape patterns. 

Alternative B identifies where fire is not desired 

and where it is likely to cause negative effects as 

well as where fire may be desired to manage 

ecosystems. 

Alternative B identifies the types and amounts of 

fuels treatments that could be reasonably 

anticipated over the next decade and the effects 

on resources that might be caused by the types 

and amounts of treatments. The revised EA also 

addresses issues raised in public comments. 

Some comments were addressed by the 

management direction provided in section 

2.5.3.1 of the EA. Other comments, such as the 

concern about sage grouse habitat, were 

addressed by specifying anticipated types and 

levels of activity in Chapter 2 and impacts of 

those activities in Chapter 3. 

Summary of Agency and Public Participation 

The EA process was announced in letters sent to 

over 5,000 potentially interested parties, 115 

agencies, and 48 fire wardens. About 750 

individuals, agencies, and organizations 

expressed a desire to remain on the mailing list. 

During the development of the EA, BLM 

representatives provided briefings to other 

agencies, county commissioners, groups, and 

organizations across Montana and the Dakotas. 

The EA was released in August 2001. The BLM 

received 31 letters with comments. Five letters 

were from agencies, 22 were from individuals, 

and six were from interest groups and other 

organizations. Comments on the initial EA 

addressed NEPA adequacy; fuels management; 

and environmental effects on wilderness, 

vegetation, sagebrush ecosystems and sage 

grouse habitat, and other wildlife. The scope of 

analysis was expanded to consider mechanical 

fuels treatments and chemical weed treatments in 

response to public comment and internal policy 

direction. 

The revised EA was made available for public 

review and comment in May 2003. Four 

additional comments were received; three from 

agencies and one from industry. Comments and 

responses to these comments are summarized in 

Chapter 4.0 of the EA. 

Implementation 

Upon signing this Decision Record, all RMPs 

will be amended to incorporate the fire 

management zone categorizations, the level of 

treatments, and the appropriate guidance and 

direction to protect other resources. Specific 

amendments for the Big Dry, Powder River, 

Judith, Valley, Phillips, West HiLine, and 

Billings RMPs as described above will also be 

implemented. 

Finding of No Significant Impact (FONSI) 

I based my finding of No Significant Impact 

(FONSI) on the information contained in the 

Fire/Fuels Management Plan Environmental 

Assessment/Plan Amendment for Montana and 

the Dakotas. The FONSI was attached to the 

EA for review during the public comment period 

from May 9 – June 9, 2003. No additional 

significant impacts or issues were raised by the 

public during the public comment period (May 9 

- June 9, 2003), during the Governors’ 

consistency reviews (July-August, 2003), or 

during the protest period (July 31-August 30, 

2003). An Environmental Impact Statement 

(EIS) does not need to be prepared. 

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